The revised Water Permit for Freshwater Tissue is on the Northcoast Water Board site under tentative orders.  They have the cease and desist order scheduled for June 10, 2010 and the permit for July 15, 2010.  Comments from citizens, one environmental organization, Evergreen Pulp and Freshwater Tissue are also there. 

It will take more time to absorb all the changes, but a few stand out. The mill has been granted an exception to the suspended solids standard in the Ocean plan, but it can be changed. "If the State Water Board revises, reissues or revokes the Facility's Ocean Plan exception for the discharge of solids from its water treatment plant, the Regional Water Board may reopen this order and make modifications in requirements in this order related to this discharge."

A long list of chemicals and heavy metals that have to be monitored has been added to the permit including hexavalent chromium, arsenic, cadmium, copper, mercury, cyanide, nickel and many others. 

They leave open the possibility that the order may be reopened and effluent limitations established.  They mention the possibility that the order may be reopened and changed in several places.

We may have more comments once we have a chance to look at the permit in more depth.
The meeting on the water permit for Freshwater Tissue has been changed to July 15, 2010.  Changes are being made in the permit and a new 30 day comment period is opening.  Comments can only be made on the changes.  The deadline is June 28, 2010.  The revised draft permit and the response to comments on the first draft will be available at the close of business on Friday.  Changes will be indicated with underlines and strikeouts.
The final decision on postponing the hearing on the water permit for Freshwater Tissue Co. will be made this week.  There are revisions being made in the permit.  The revisions will be published for  public comment (30 days).  The probable date of the new hearing is July 15, 2010.
Most of us are not scientists and are not familiar with the term biological oxygen demand.  Bob Simpson of Freshwater Tissue says, "In short BOD is organic sugar.  You could just as easily refer to BOD as fish food or plant nutrients." (Humboldt Herald) This sounded a little improbable to us, so we looked it up.

Apparently, a high BOD indicates polluted water. Dissolved oxygen is consumed by bacteria when large amounts of organic matter from discharges are present in the water. When oxygen drops below a certain level, fish and other aquatic life die.  Also, growth of weeds and other types of growth can make significant changes in a body of water.

Mr. Simpson acknowledges that this could be a problem in rivers, but not in the Pacific Ocean.  The problem, he says is the EPA standard.  He thinks he knows better.  Mr. Simpson seems to have an outdated view of the environment and the cvondition of the oceans worldwide.
Back when pulp mills started in Humboldt County, it was thought that the oceans were endless.  We could put any kind of pollution in the Ocean and it would absorb it or so they thought.  Now we know differently. Plastic bags sit in an island in the middle of the Pacific.  There are dead zones in the Ocean where there is not enough oxygen to support aquatic life. And then there is the Gulp BP oil spill.  The viable Ocean and coastline of the United States may be permanently damaged.  Mr. Simpson and Freshwater Tissue plan to keep putting B.O.D.s in the Ocean in excess of EPA standards until Sept. 2013.

Mr. Simpson said in the same article, "The only pollution the Samoa Mill cannot comply with is its biochemical oxygen demand."  A look at the violations that led  to the mill losing its water permit shows this is not true.  They were also fined for exceeding the allowed amount of Total Suspende Solids, Absorbable Halides and Aldrin.

For anyone who has not been following this, The Water Board will consider the Water Permit for Freshwater Tissue Co. on June 10, 2010 in Santa Rosa.  This permit will allow them to break the Clean Water Act until Sept 2013 and not be fined for violations in the production of umnbleached pulp.                                     

This is what can be proven:

California has a list of chemicals that are known to cause cancer and birth defects (proposition 65). The list of these chemicals is available online.

In the proposed Water Permit (hearing date June 10, 2010) certain chemicals must be monitored because they have been detected in mill emissions or are likely emissions of this pulp mill. They include prop. 65 chemicals such as arsenic, aldrin, benzene, mercury, nickel, hexavalent chromium, DDT and many others. The draft permit is online.

There are 13 wells at the mill site. The last recorded test (2008) reveals many prop. 65 chemicals including arsenic, chromium, manganese, benzene, chromium, hexavalent chromium, nickel and many others. Many of the listed chemicals are above the reporting level some as high as 1000 times.

This is why Louisiana Pacific is being force to clean up the site. Evergreen would have been involved, but it skipped town. This information is available at the State Water Board Geotracker site.

A health risk assessment was done in 2006. Although it was done by a company hired by Evergreen Pulp, it had some interesting findings. Among the chemicals listed as toxic air contaminants are a number of prop. 65 chemicals including acetaldehyde, benzene, carbon tetrachloride, chloroform, ethyl benzene and formaldehyde. The cancer risk at the point of maximum impact is 35 in one million far above the significant cancer risk level of 10 in one million. This site is located on the north fence line. IT WOULD SEEM THAT IF IT IS THIS HIGH NEAR THE PLANT, IT WOULD IMPACT THE WORKERS ON THE MILL SITE. They target hexavalent chromium and acetaldehyde as the chemicals that contribute the majority of the cancer risk. There is a scary list of toxic emissions at the end of the report many of which are on the prop.65 list of cancer causing agents. Parts of this health risk assessment can be downloaded on this site.

The mill has a long list of violations including having their water permit revoked in 2009. We will say more about all the violations in future articles. The mill is old and has frequent breakdowns which cause toxic emissions. Looking back we found a report by Tetra Tech in 2005 after an inspection of the mill which reported “visible entrained grey to black particulate matter circulating inside the recovery boiler building; grey powder accumulation on handrailings inside building,” “Pulp debris from various process stages on cement floor of downstairs of process building. Debris formed a sort of dry carpet of pulp and grey/black ashy material on cement pad outside near the sulfur tank/caustic operations area and drains.” While this may have been cleaned up, ONE CAN ONLY WONDER WHAT CHEMICALS THE WORKERS WERE BREATHING AT THAT TIME.”

All of the above are part of the public record and can be checked.

A google search for cancer and pulp mill workers has 18,600 entries. The studies of pulp mill workers are many. We will cover some of these in future articles. Some of the diseases that are prevalent among workers are leukemia, non-hodgkins lymphoma, methothelioma and cancers of the digestive system.

Only the pulp mill workers know how many of their fellow workers have come down with cancer or died from it.

Pulp mill workers don’t take our word for it. Look up the studies. Check with the Air and Water Boards for information. Then ask yourself, “AM I WILLING TO RISK MY LIFE FOR FRESHWATER TISSUE?”

If you or I break the law, we must pay the price.  We cannot apply for an exemption from the law or from fines and penalties.  But, this is exactly what Freshwater Tissue Co. is asking for, an exemption from the Clean Water Act and penalties until Sept. 2013.

There is still the perception that Freshwater will be operating up to code if it gets the water permit on June 10, 2010.  It will not.  Somehow people heard all the propaganda about how Freshwater was going to open a green pulp mill and this is what they remember.  Freshwater doesn't have the money to do all the things it talked about when it was hoping to get money as part of the government stimulus program.  It did not get this money.  Now it is planning a shoestring operation hoping to get investors once it gets the water permit.  This is not going to be a green operation.  It has asked for permission to break the clean water act until Sept. 2013.  It will not be up to code.

Don't take our word for it.  To quote Charles Reed of the Water Board staff. "...the wastewater discharge from the pulp mill during production of unbleached pulp cannot comply with the final effluent limitations for five-day biochemical oxygen demand (BODs) and total suspended solids (TSS) that are established in the tentative permit.  Freshwater Tissue Company requested a compliance schedule that will allow three years from the mill startup to obtain required local development permits, and design and construct a conventional activated sludge wastewater treatment plant...Violations of final effluent limitations for BODs and TSS ...during the production of unbleached kraft pulp will not be subject to Mandatory Minimum Penalties under California Water Code."

For copies of the proposed permit and the cease and desis order, go to decisions/tentative orders

There is a new letter on Geotracker dated May 4, 2010 from the Water Board to Louisiana Pacific and Freshwater Tissue.  It approves a new schedule for the cleanup.  Details of the schedule are included in a letter dated April 20, 2010 from SHN Consulting of Eureka the company that is working on the cleanup.  We will find out more about this. Apparently there was some monitoring of the wells in 2010, but the results are not available yet. Louisiana Pacific is responsible for the cost of the time the Water Board staff spends on the cleanup.

The consulting firm SHN Consulting is doing a feasibility study that looks at options for cleanup.  When they have determined that there are one or two options that look promising, they will do a pilot study.
At that time there will be a public comment period.

Greenwashing is presenting a public image that implies that the company is protecting the environment while it is really polluting for profit.  Both Freshwater Tissue and Evergreen Pulp picked names that create an image that is appealing to people who care about nature.  Freshwater puts a lot of pictures of trees on their website.  Those of us who attended the air meetings remember the green T shirts the Evergreen workers wore.  Now Freshwater has "Environmental Facts" on their website.  These consist of water reports all 1997 and before and a few quotes from the only studies they could find that even suggest that pulp mills could be OK, one from Ch2Mhill funded by Evergreen and one from Johns Hopkins 1997. (They do not quote the parts of the study that show increased cancer rates.)

They don't include in their Environmental Facts that the mill had its water permit revoked in 2008.  They don't mention the fines which could have been as much as $59,297,999,000 but were only $463,000.
These violations were from 2005 to 2007. There were more violations in 2008 that were not included in this fine.  These violations were for excess BODs (Biological Oxygen Demand(), TSS (Total Suspende Solids) and AOX (Absorbable Organic Halides). The amount discharged in Excess of 1000 gallons and not cleaned up is in the billions of gallons.  They don't mention the air violations.

We remember how Freshwater Tissue Co. made all the claims about how green they were going to be.  Now they are asking for a Water Permit where they admit that they can't comply with the Clean Water Act until September 2013. GREEN?